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DJI

Contribute to a regulatory framework that ensures safe use of remotely piloted aircraft and safe skies open for innovation, to harness the potential for growth and job creation.

Lobbying Activity

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Gaëlle Michelier (Cabinet of Commissioner Adina Vălean)

20 Sept 2020 · Presentation meeting

Response to Detailed rules on unmanned aircrafts

2 Nov 2018

DJI supports the European Commission’s latest draft delegated regulation setting technical requirements for drones in the Open Category. However, there are still some urgent areas needing to be addressed or clarified. An extended version of this contribution was uploaded as an annex. (1) C0 class: DJI would like to highlight that most of the drones in this category, at 250g or below, are toys without GPS functionalities and with limited connectivity, leaving remote ID difficult to implement. (2) C1 class: We call for a better explanation of measurement with regard to the ‘80 J shock to human head’ benchmark, as no standard measures this. Technical clarity would also be needed on the provisions on drone lights. (3) Follow-me requirement: The limitation to a 50m distance as a product requirement when a C0 or C1 drone is in “follow-me” mode neglects the technical complexity of the subject and the fact that the pilot remains fully in control. In situations where the pilot is not followed but uses the drone to track something else, he/she remains fully in control, and remains subject to the VLOS and default height requirements in the Open Category. Rather than an autopilot mode, this is an assistive technology that enables pilots to get smooth and stabilized images of an in-focus subject that even very experienced drone pilots cannot match. For this reason, a 50m limitation should not apply when following a subject/object other than the pilot as this will severely restrict the utility of this technology. When following the pilot while he/she is doing something else, control is indeed more limited and the analogy with an autopilot mode can be made. As a consequence, safety concerns become more prominent. However, technical impediments complicate the enforcement of a 50m maximum distance as a product requirement. A possible solution would be to make a clear distinction between the two existing automated tracking modes: follow-me (pilot not/much less in control) and follow-something/someone-else (pilot in control). Due to the lack of open technological solutions, we can only envisage the distance requirement as an operational requirement. In the latter, where a pilot remains in full control, general operational requirements should apply. Fully in line with the EASA Opinion, keeping the possibility for the pilot to regain control or to activate an emergency procedure, should be kept in the text as a product requirement applicable to both versions of a follow-me mode in control when he/she is the object of tracking by the drone, technical impediments should lead any distance requirement with regards to follow-me mode to be a broadly defined operational requirement. Note the wording ‘mode of operation of a UAS’ in the current definition also. (4) We believe some excessive administrative burdens are still in the draft text. The labeling requirements go beyond the general CE-marking rules. It is essential that drones are not treated differently than other technology. In addition, the requirement to list all compatible third-party software will be outdate at the moment of sale due to the constant evolution of software environments. (5) With regard to the noise test code, we do not understand the rationale behind testing a UAS at hover power but to keep it fixed to a solid surface. Drone noise should be measured in a situation as close to real-life use as possible: at hover speed, while hovering. Given the exclusion of fixed-wing drones from noise levels requirements, attaching the drone to a fixed platform is also no longer necessary. We would also invite to make sure that legitimate environmental concerns on noise do not limit the use and safe operations of drones. We point out that some accessories increasing security might as well increase the noise emissions (e.g. rotor cages). We therefore recommend exempting those from the noise measurement procedure.
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Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

7 Sept 2018 · Meeting on drones

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

11 Jun 2018 · Civil drones

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

14 Nov 2017 · Meeting with Christian Struwe, Head of Public Policy for Europe at DJI

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

2 Feb 2017 · U-Space and EASA Regulation